JONES, Chief Judge.
The plaintiff, an accrual basis taxpayer, seeks to recover alleged overpayments of its Federal income taxes for the years 1947, 1948, and 1949. The initial issue concerns the taxpayer's claim of exemption from taxation under § 101 (10) of the Internal Revenue Code of 1939, 26 U.S.C.A. § 101(10). The alternative issue involves the tax treatment of prepaid annual membership dues.
The organization and the functions of the taxpayer...
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